1. The Defendant’s value-added tax for the first term of November 1, 2011 (including penalty tax) for the Plaintiff on November 1, 2014, KRW 106,882,880;

1. Details of the disposition;

A. On April 15, 2007, the Plaintiff is an association with the approval of the establishment promotion committee from the head of Nam-gu Incheon Metropolitan City, and with the approval of the establishment of the association on October 4, 2010.

B. The Plaintiff promoted a housing redevelopment project in the first and second taxable periods in 2011, and second taxable periods in 2011, received a purchase tax invoice of KRW 4,137,50,484 from J.C., the total supply price of KRW 4,137,50,484, and received KRW 413,755,047, as the common purchase tax amount for the tax-free business, and received KRW 139,683,442, which is related to the taxation, excluding KRW 274,071,605, among them, by filing a final tax return and filing a correction claim.

C. Around July 2014, the Defendant issued a revised notice on November 1, 201 of value-added tax amount of KRW 106,82,880 (including additional tax of KRW 33,60,139), value-added tax of KRW 36,685,940 (including additional tax of KRW 10,532,137) for the second period of February 201, 201, on the ground that services falling under the tax invoices of KRW 2,763,52,00 among the above purchase tax invoices received by the Plaintiff (hereinafter “instant tax invoices”) are not subject to pro rata distribution of the common purchase tax amount, but the tax amount related to capital expenses for the creation, etc. of land, etc., and excluded the Plaintiff from those subject to the refund of the input tax amount.

(hereinafter “instant disposition”) D.

The Plaintiff dissatisfied with the instant disposition and filed a request for examination on February 9, 2015, but the Commissioner of the National Tax Service dismissed the request on April 7, 2015.

[Ground of recognition] The facts without dispute, Gap evidence Nos. 1 through 4 (including the branch numbers in the case of additional numbers), Eul evidence Nos. 1 and 2 (including the branch numbers in the case of the evidence No. 1), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The instant services provided by the Plaintiff from the Jinjin Co., Ltd., etc. shall be services and consulting services necessary for redevelopment projects, such as the draft of consent to the establishment of the association, and the establishment of maintenance plans, etc.